Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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AAR held that the proposed imports, Air Start Unit (ASU) GS-400 and Air Conditioning Unit (ACU) GF-50, are classifiable as aircraft parts under CTH 8807 30 10. Applying Section XVII Note 3, AAR found both units are engineered solely and principally for aircraft operation, have exclusive aircraft couplings/parameters, and lack any plausible general-purpose use, thus not being "parts of general use" excluded by Note 2. Relying on the SC ruling in Commissioner v. Mak Controls and subsequent CESTAT application, AAR concluded that such ground-based units functioning as APU-off substitutes form integral parts of aircraft systems and must be classified under heading 8807 30 10.
AAR held that the proposed imports, Air Start Unit (ASU) GS-400 and Air Conditioning Unit (ACU) GF-50, are classifiable as aircraft parts under CTH 8807 30 10. Applying Section XVII Note 3, AAR found both units are engineered solely and principally for aircraft operation, have exclusive aircraft couplings/parameters, and lack any plausible general-purpose use, thus not being "parts of general use" excluded by Note 2. Relying on the SC ruling in Commissioner v. Mak Controls and subsequent CESTAT application, AAR concluded that such ground-based units functioning as APU-off substitutes form integral parts of aircraft systems and must be classified under heading 8807 30 10.
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